EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

section 143(3) of the Act, in the Assessment Year 2003-2004. 8. The CIT has allowed the average cost worked out by the assessing officer for the assessment year 2003 - 04 in the case of M/s Vectra Holdings P Limited, an associate company fo the appellant. ITA Nos.1569, 1600, 1607 & 1608/Bang/2014 Page

EPSILON ADVISORS P. LTD.,,BANGALORE vs. CIT, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

section 143(3) of the Act, in the Assessment Year 2003-2004. 8. The CIT has allowed the average cost worked out by the assessing officer for the assessment year 2003 - 04 in the case of M/s Vectra Holdings P Limited, an associate company fo the appellant. ITA Nos.1569, 1600, 1607 & 1608/Bang/2014 Page

DCIT, BANGALORE vs. M/S EPSILON ADVISORS PVT. LTD.,, BANGALORE

In the result, penalty appeal of the assessee is allowed and penalty appeal of the revenue is dismissed

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

section 143(3) of the Act, in the Assessment Year 2003-2004. 8. The CIT has allowed the average cost worked out by the assessing officer for the assessment year 2003 - 04 in the case of M/s Vectra Holdings P Limited, an associate company fo the appellant. ITA Nos.1569, 1600, 1607 & 1608/Bang/2014 Page

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain or as business income, ITA Nos.542 to 544/Bang/2021 & CO Nos.17 to 19/Bang/2021 Sri Mathikere Ramaiah Seetharam, Bangalore Page 49 of 96 which issue not required to be answered at this stage as the income is not accrued in these assessment years. The quantum of applicability of Accounting Standard-9 with regard to revenue recognition is not required

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain or as business income, ITA Nos.542 to 544/Bang/2021 & CO Nos.17 to 19/Bang/2021 Sri Mathikere Ramaiah Seetharam, Bangalore Page 49 of 96 which issue not required to be answered at this stage as the income is not accrued in these assessment years. The quantum of applicability of Accounting Standard-9 with regard to revenue recognition is not required

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-2(1), BANGALORE vs. SRI MATHIKERE RAMAIAH SEETHARAM, BANGALORE

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain or as business income, ITA Nos.542 to 544/Bang/2021 & CO Nos.17 to 19/Bang/2021 Sri Mathikere Ramaiah Seetharam, Bangalore Page 49 of 96 which issue not required to be answered at this stage as the income is not accrued in these assessment years. The quantum of applicability of Accounting Standard-9 with regard to revenue recognition is not required

M/S UNITED BREWERIES LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

capital gain from the sale of shares and further erred in not adjudicating on this crucial issue by holding that this is academic in nature 7.5 The learned CIT(A) has erred in confirming the action of the AO in making the addition, by making a frivolous observation that there is nothing on record to show that the copy

ESTATE OF LATE DR. S. ZAKAULLA MASOOD,BENGALURU vs. INCOME TAX OFFICER, WARD-1(3)(4), BENGALURU

In the result, the appeal of the assessee is accordingly allowed

Bench: Shri N.V. Vasudevan & Shri A K Garodiaassessment Year: 2010-11

section are ‘purchased’ or ‘constructed’. The condition precedent for claiming benefit u/s 54F is that the capital gain should be parted by the assessee and invested either in purchasing a residential house or in constructing a residential house. Merely because the sale deed had not been executed or that construction is not complete

M/S. S I MEDIA LLP, ,BENGALURU vs. DCIT, CIRCLE-1(1)(1), BENGALURU

In the result appeal of the assessee allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

302, Brigade Lavelle, Income Tax, Lavelle Road, Circle – 1[1][1], Bangalore – 560 001. Bangalore. PAN – ACWFS 9656 C APPELLANT RESPONDENT Assessee by : Ms. Sunaina Bhatia, Advocate Revenue by : Shri Subramanian S, JCIT (DR) Date of hearing : 07.04.2025 Date of Pronouncement : 29.05.2025 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: This is an appeal filed by the assessee

M/S NITESH ESTATES LIMITED ,BANGALORE vs. THE ASSISTANT DIRECTOR OF INCOME TAX (INTL TAXN) CIRCLE-1(2), BANGALORE

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2011-12

capital gains has been arrived at, as against loss claimed. 3.8 In view of the above facts and the provisions of law, he placed reliance on the order of ITAT Chandigarh Bench held in the case of Harpal Singh, ITA NO 37/Chd/2016, order dated 08/08/2018 that assessee cannot be absolved of the responsibility to deduct taxes (and interest). The relevant

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

SHRI. VADAGUR NARAYANAPPA PREMACHANDRA,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(1), BANGALORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.

302 ITR 286 (Mad) in the case of CIT vs. Sardarmal Kothari and Anr., cited by the assessee in which it was held as follows: “Held, dismissing the appeals, that admittedly the assessees had purchased the land by investing the capital gains and had constructed residential houses. Circular No. 667 dated October

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

capital investment in a partnership firm cannot be considered on par with investment in equity and therefore. such investment cannot be considered as for the purpose of earning exempt income, all the more so for the reason that the profits of the partnership firm are taxed in the hands of the firm and hence, not taxed in the hands

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(3), BANGALORE vs. M/S COFFEEDAY GLOBAL LIMITED , BANGALORE

In the result, the appeals of the Revenue are partly allowed

Bench: S/Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm Ita Nos. 3040 & 3041/Bang/2018 Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Coffee Day Global Limited, Income-Tax, Central Circle-1(3), No.23/2, Coffeeday Square, 3Rd Floor, C.R. Building, Vittal Mallya Road, Queen’S Road, Bengaluru-560 001. Bengaluru-560 001. [Pan: Aabca 5291P]

capital investment in a partnership firm cannot be considered on par with investment in equity and therefore. such investment cannot be considered as for the purpose of earning exempt income, all the more so for the reason that the profits of the partnership firm are taxed in the hands of the firm and hence, not taxed in the hands

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account

DCIT, BANGALORE vs. M/S CISCO SYSTEMS INDIA PVT. LTD.,, BANGALORE

In the result, the Revenue’s appeal as well as Assessee’s appeal are partly allowed for statistical purposes

Section. 7 IT(TP)A No.505-508 & CO 135/Bang/2015 M/s.Cisco Systems (India) Pvt.Ltd. 3. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in directing the AO to compute deduction u/s 10A in the above manner by placing reliance on the decision of Hon'ble High Court of Karnataka in the case of M/s Tata

CISCO SYSTEMS (INDIA) PRIVATE LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the Revenue’s appeal as well as Assessee’s appeal are partly allowed for statistical purposes

Section. 7 IT(TP)A No.505-508 & CO 135/Bang/2015 M/s.Cisco Systems (India) Pvt.Ltd. 3. On the facts and in the circumstances of the case the Dispute Resolution Panel erred in directing the AO to compute deduction u/s 10A in the above manner by placing reliance on the decision of Hon'ble High Court of Karnataka in the case of M/s Tata